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Comm out for repair

Old 7th Mar 2019, 13:03
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Comm out for repair

Would anyone know the answer to the following. Our aircraft which is fitted with 2 comms needs one of them repaired. At our location there is no radio repairer so it has to go interstate for repair. The LAME that is removing the faulty unit tells me that once he removes it, this gets entered into the MR and we are grounded until it gets back? This doesn't sound correct to me. For IFR ops and even NVFR for certain flights to PAL operating airfields certainly, but day VFR? Why would this be as I have flown many VFR aircraft with only 1 comm fitted over the years. Anyone know the truth of the matter and where I can find this in the regs?
mostlytossas is offline  
Old 7th Mar 2019, 13:30
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VFR no problems, IFR single VHF and HF is the only legal solution, plus some fuel I think for the brothers to turn the lights on if it’s at night if I recall correctly.
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Old 7th Mar 2019, 13:33
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Maybe you need to get an engineering order to remove the radio (temporarily or otherwise) since that is a modification of sorts?
Not quite as straightforward as disabling/placarding an unserviceable instrument and running on 20.18 requirements.
Fred Gassit is offline  
Old 7th Mar 2019, 13:38
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Originally Posted by Fred Gassit View Post
Maybe you need to get an engineering order to remove the radio (temporarily or otherwise) since that is a modification of sorts?
Not quite as straightforward as disabling an unserviceable instrument and running on 20.18 requirements.
Unless you have an MEL that allows for it your LAME is correct.
You may be able to get a permit from CASA.
FWIW
Eddie Dean is offline  
Old 7th Mar 2019, 14:03
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Day VFR equipment | Civil Aviation Safety Authority

The flight and navigational instruments required for flights under visual flight rules are:
  • an airspeed indicating system
  • an altimeter, with a readily adjustable pressure datum setting scale graduated in millibars
    one of the following
    • a direct reading magnetic compass or
    • a remote indicating compass and a standby direct reading magnetic compass; and
  • an accurate timepiece (clock or watch) indicating the time in hours, minutes and seconds.
CAO 20.18
Other aircraft in private, aerial work or charter operations
3.4 Subject to paragraph 3A.3, an aircraft:
(a) engaged in a private, aerial work or charter operation; and
(b) not mentioned in paragraphs 3.1 to 3.3;
may only be operated under the V.F.R. if it is equipped with the following:
(c) the instruments specified in Appendix I;
(d) any other instruments and indicators specified in the aircraft’s flight manual.

So what does your Flight Manual say? If it says you require 2 then that would be why, also, is the remaining Radio properly certified for use? Wouldn't be the first time one has been installed and certified with a cheaper backup that wasn't.
Ixixly is online now  
Old 7th Mar 2019, 14:52
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Many LAMEs think that, the moment an entry is made in the MR, the aircraft is grounded until that entry is "cleared". This is not true, and I will find the CAR references tomorrow, if you wish.

The regs are very clear that only a "major defect" can cause the MR to "cease to be in force" (i.e. aircraft is grounded), and examples are given of what constitutes "major defects". A removed radio is certainly not a major defect and does not even come close to being one.
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Old 7th Mar 2019, 23:04
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FGD - while I agree with you, it seems CASA's (current) interpretation is that any MR entry renders the aircraft unairworthy. This is in contradiction to various CARs but follows on from others $^@%%!!! Never look for consistency.

A workaround might be to remove the radio and placard the associated bits U/S. (Because the pilot might inadvertently attempt to use the blank gap in the panel )
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Old 8th Mar 2019, 02:09
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I would be ok to let it fly in vfr Airwork or vfr private for a month but if your a/c is charter then there needs to be a Mel in place
i can sort of see your LAMEs view as these days of over zealous AWI,s no one wants to put their neck out
Ethel the Aardvark is offline  
Old 8th Mar 2019, 05:00
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FGD - while I agree with you, it seems CASA's (current) interpretation is that any MR entry renders the aircraft unairworthy. This is in contradiction to various CARs but follows on from others $^@%%!!! Never look for consistency.
Thanks, drpixie.

So, if my seat has developed the occasional little squeak, or the armrest has gotten a little wobbly, and I record that on the MR, then my aircraft is grounded?
FGD135 is offline  
Old 8th Mar 2019, 05:16
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An entry only effects a flight where that entry would effect that particular next flight, unless as mentioned the M/R is endorsed "Aircraft unserviceable" or words to that effect. EG: Clock in control column (Beech A36, B200 Etc) U/S does NOT ground the A/C as long as you carry a time piece!
machtuk is offline  
Old 8th Mar 2019, 06:11
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Your Flight Manual will list all your equipment in that aircraft.

Yours should list the two comms - if you get ramped and they only find one, you will certainly be grounded.

An EO can be applied for to remove the unit for x amount of time and some conditions/limitations be made, like blanking the hole, placards and pulling and securing the CB.

In short having one of your two comms U/S is not breaching operations of the 20.18 requirements, but removing the unit is a completely different thing.

If you have an aircraft that has two turn and bank indicators and one is broken (stuck) you can not just remove the U/S one and keep flying around. It could be feeding information to other systems like the AP so now you start to get multiple failures or part failures. That's why you need an EO.
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Old 8th Mar 2019, 06:54
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Originally Posted by FGD135 View Post
Thanks, drpixie.

So, if my seat has developed the occasional little squeak, or the armrest has gotten a little wobbly, and I record that on the MR, then my aircraft is grounded?
According to current CASA "thinking" - absolutely yes - anything on the MR grounds it. (Excepting MEL items, which are closed by the reporting pilot and turned into scheduled items!)

The days of using the MR as a useful "to do" list are over. If you record the nav light u/s, you must send the aircraft to maintenance - can't even use it for day vfr. Does this encourage us to leave things of the MR? To keep a separate squawks list? Absolutely. Counter-productive? Absolutely. Degrades PIC responsibility? Yup.
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Old 8th Mar 2019, 10:44
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My last dealings with the CASA boys in the west was that there should be no open defects on a mr. ie nav light us. Should be written up in clearing endorsement as not required for day vfr flight.
Look in casa maintenance guide for pilots
therefore if a pilot can perform a globe change he is entitled to clear the endorsement.
I believe it’s a odd way to do it as technically it’s still an open defect but who am I to argue.
Ethel the Aardvark is offline  
Old 8th Mar 2019, 12:39
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CAAP 43-01 v2.0 covers it quite well. Section 4.2

https://www.casa.gov.au/sites/defaul...ce-release.pdf

As far as the original post - 1 of 2 Coms U/S - that would probably be fine if so endorsed as not a major defect and not required for VFR .

1 Com Removed - needs an EO.
Kiwiconehead is online now  
Old 8th Mar 2019, 22:50
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Originally Posted by drpixie View Post
FGD - while I agree with you, it seems CASA's (current) interpretation is that any MR entry renders the aircraft unairworthy. This is in contradiction to various CARs but follows on from others $^@%%!!! Never look for consistency.

A workaround might be to remove the radio and placard the associated bits U/S. (Because the pilot might inadvertently attempt to use the blank gap in the panel )
That placard would be "do not store your mobile phone in here - it will get hot and catch fire"
Bend alot is offline  
Old 9th Mar 2019, 01:21
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swh

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Originally Posted by mostlytossas View Post
Would anyone know the answer to the following. Our aircraft which is fitted with 2 comms needs one of them repaired. At our location there is no radio repairer so it has to go interstate for repair. The LAME that is removing the faulty unit tells me that once he removes it, this gets entered into the MR and we are grounded until it gets back? This doesn't sound correct to me. For IFR ops and even NVFR for certain flights to PAL operating airfields certainly, but day VFR? Why would this be as I have flown many VFR aircraft with only 1 comm fitted over the years. Anyone know the truth of the matter and where I can find this in the regs?
The part you have missed here is what operational category and operations are permitted on the M/R. You cannot remove a comm and fly it VFR if your IFR and Charter operational category. You need to comply with categories the M/R was issued with, or endorse a change of the operational category on the M/R.

Basically the M/R must tell someone that is totally unfamiliar with the aircraft what operations and operational category is permitted for the next flight.

The regulations do not differentiate between owner operators and aircraft for hire, the M/R is a “safety certificate” issued on behalf of CASA that will tell any person who will operate or work on the aircraft it’s current status.

On larger aircraft we would apply an MEL, and as a consequence of a MEL item we may need to raise an additional entry/entries stating only for day VMC, only for private operations, no ETOPS, no LVO etc.
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Old 9th Mar 2019, 01:26
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Aren't we looking at two problems here?

One: The U/S Radio, which if not removed, could probably allow the A/C to continue flying albeit with some restrictions till repaired. Either an MEL or AFM Sup might help?
Two: Removing the U/S Radio. If it's removed, you've effectively now modified the A/C which will render it grounded, unless you get an approval (Engineering Order).

Is it possible for you to fly the A/C to facility capable of repairing the defect?
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Old 9th Mar 2019, 02:57
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I found the best option was a loan unit, this can often be supplied from the shop doing the repair at a small fee + freight.

I once heard a bloke that knew a bloke say that "loan units can often be found on eBay. You install them and they test "fine" and get signed off in the Log Book (not MR)- next attempt for some reason it goes U/S. The faces all look the same and an AWI is not going to remove your radio's to check S/N's - Thats the ATSB's job.

Flying to a facility will cost ferry hrs and down time. Not often they will jump straight onto your com - needs to be left a few days to adjust to the workshop room temperature before it can be touched by the Bench Tech's bare hands. There is only one problem, and that is once the unit is removed the aircraft is grounded until a) the com is replaced, b) An EO is granted, c) A permit is granted by CASA - gave up on that many years ago.
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Old 9th Mar 2019, 05:55
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CAR 42Z Removable items of radiocommunications equipment in VFR aircraft—exemption from certification requirements:
can this apply???
Ethel the Aardvark is offline  
Old 9th Mar 2019, 06:44
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A com is not a removable item of radio communications equipment (normally).

That would be more a hand mic or a headset or even a ELT listed in the Flight Manual.

42Z is an exemption of a certification for a "replacement" part, not an exemption to fly with item removed.
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